Seating devices for bodily restraining children traveling in automobiles are commonplace, and are the object of many patents. These devices typically restrain the child's torso, preventing it from being thrown forward in the event of an impact. While these devices reduce the likelihood of bodily injury to the child, the potential for hyperextensive injuries of the neck, more commonly known as "whiplash", remains high. Such injuries are particularly dangerous for small infants whose neck muscles are not yet capable of fully supporting the head.
U.S. Pat. No. 4,339,151, to Riggs, discloses an adult head restraint comprising a headband attached to a strap wrapped around the chair. The Riggs device is capable of providing only a limited degree of restraint against forward motions of the head, and provides no resistance to lateral motion of the head to either side. In addition, the direct physical contact between the Riggs device headband and the user's head could prove uncomfortable and unduly restraining to the user.